ML20054M572
| ML20054M572 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/11/1982 |
| From: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Oprea G HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20054M566 | List: |
| References | |
| NUDOCS 8207130622 | |
| Download: ML20054M572 (18) | |
Text
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11 MAY 7932 i
Dockets:
50-498/81-37 50-499/81-37 Houston Lighting and Power Company ATTN:
Mr. G. W. Oprea, Jr.
Executive Vice President P. O. Box 1700 Houston, TX 77001 Gentlemen:
This refers to the Systematic Assessment of Licensee Performance (SALP) Board Report of the South Texas Facility, Units 1 and 2, Construction Permit CPPR-128 and CPPR-129.
The SALP Board met on September 11, 1981, to evaluate the performance of the subject facility for the period July 1, 1980, through June 30, 1981.
The performance analyses and resulting evaluation are documented in the enclosed SALP Board Report.
These analyses and evaluation were discussed with you at your office in Houston, Texas, on October 16, 1981.
The performance of your facility was evaluated in the following functional areas: Containment and other Safety-Related Structures; Support Systems; Licensing Activities; and Corrective Action and Reporting.
The SALP Board evaluation process consists of categorizing ~ performance in each functional area.
The categories which we have used to evaluate the performance of your facility are defined in Section-II of the' enclosed SALP Board Report.
As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staff.
This report is consistent with the revised policy.
Any comments which you may have concerning our evaluation of the performance of your facility should be submitted to this office within 20 days of the date of this letter.
Your comments, if any, and the SALP Board Report, will both appear as enclosures to the Region IV Administrator's letter which issues the SALP Report as an NRC Report.
In addition to the issuance of the report, this letter will, if appropriate, state the NRC position on matters = relating to the status of your safety program.
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/82 4/19/82 4/ >?/824 4/ /82 ' //#/82 8207130622 E20618 PDR ADOCK 05000498 PDR G
Houston Lighting and Power 2
j[I I'I47 U32 Company Comments which you may submit at your option, are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
Orialnal Signed by:
G. LL MADSEN
G. L. Madsen, Chief Reactor Project Branch 1 En' closure:
Appendix - NRC Report 50-498/81-37 50-499/81-37 (Lo b/hs,sr. g cc to DMB (IE ) Th 6 7's bcc distrib. by RIV:
C W. Crossman P
W. Hill A D W. Seidle EL D. Sells, NRR IE ILE H. Phillips
'IE/ RI W. Hubacek NRR/
R. Stewart NRR/
J. Tapia RAD MT BR J. Collins RES A :CH RPB2 P :HQ TPB DR I C, Wisner NSIC L%iC SYSTEM NTIS TEXA DEPT. OF 'E.^.Lin RESCURCES-RIV FILE 1
APPENDIX-U. S. NUCLEAR REGULATORY COMMISSION REGION IV Systematic Assessment of Licensee Performance Report:
50-498/81-37 50-499/81-37 Dockets:
50-498 & 50-499 Category A2 Licensee:
Houston Lighting and Power Company P. O. Box 1700 Houton, Texas 77001 Facility Name:
South Texas Project, Units 1 and 2 Appraisal Period:
July 1, 1980-June 30, 1981 Appraisal Completion Date:
September 1, 1981 Licensee Meeting:
October 16, 1981 SALP Board:
W. C. Seidle, Chief, Reactor Project Branch 2 W. A. Crossman, Chief, Reactor Project Section B D. E. Sells, NRR Project Manager H. S. Phillips, Senior Resident Inspector W. G. Hubacek, STP Transition Coordinator R. C. Stewart, Reactor Inspector J. I. Tapia, Reactor Inspector m-7!O Reviewed by:
4 W. A. Crossman, Chief Date Reactor Project Section B Approved by:
b ) b do M A 7!81 l
W. C. Sei~dle, Chief Odte ~/
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- Reactor Project Branch 2 j
(SALP Board Chairman)
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2 I.
Introduction Systematic Assessment of Licensee Performance (SALP) is an-integrated NRC staff effort to collect available observations and data annually and to evaluate licensee performance utilizing these data and observations as a basis.
The integrated systematic assessment is intended to be sufficient-ly diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management.
II.
Criteria The assessment of licensee performance,is implemented through the use of seven evaluation criteria.
These criteria are applied to each functional area that is applicable to the facility activities (construction, pre-operation or operation) for the categorization of licensee performance in these areas.
One or more of the following evaluation criteria are used to assess each applicable functional area.
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness.to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management) 7.
Training effectiveness and qualification Attributes associated with the above evaluation criteria form the guidance for the SALP Board for categorization of each functional area in
~
one of three categories.
Performance categories are defined as follows:
Category 1:
A combination of attributes which demonstrates achievement of superior safety performance; i.e., licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Reduced NRC attention may be appropriate.
Category 2:
A combination of attributes which demonstrates achievement of satisfactory safety performance; i.e., licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that
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- 3, satisfactory performance with respect to operational safety or construction is'being achieved.
NRC attention should be maintained'at normal levels.
,c Category 3:
A combination of attributes which demonstrates achievement of only minimally satisfactory safety performance; i.e., licensee management attention or involvement is acceptable'and considers nuclear safety, but weaknesses are evident; licensee resources appear to be.
strained or not effectively used such that mi'imally satisfactory performance with respect to operational-safety or construction is being achieved.
Both NRC and licensee attention should be increased.
III. Summary of Results Functional Areas Category 1.
Soils and Foundations NA 2.
Containment and other Safety-Related 2
Structures 3.
Piping Systems and Supports NA 4.
Safety-Related Components NA 5.
Support Systems 2
6.
Electrical Power Supply and NA Distribution 7.
Instrumentation and Control Systems NA 8.
Licensing Activities 1
9.
Corrective Action and Reporting 3
IV.
Performance Analyses The SALP Board obtained assessment data applicable to the appraisal period of July 1, 1980, to June 30, 1981.
The data for the South Texas Project (STP) was tabulated and analyzed and a performance analysis was developed for each of six functional areas.
The SALP Board met on October 16, 1981, to review the performance analyses and supporting data and to develop the SALP Board Report.
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4 Functional Area Analysis 1.
Soils and Foundations All activities completed.
2.
Containment and other Safety-Related Structures Limited work has been done relative to containment concrete activities.
However, two noncompliances were identified: (a) failure to maintain / inspect traceability of imbeds, and (b) failure to test for air content of grout.
Limited work effort observed since the licensee lifted a self-imposed stop work order appeared to be satisfactorily performed.
One noncompliance was identified in the area of other safety-related structures:
failure to assure that purchased material (inspection of Nelson stud welding to embeds) conformed to procurement documents.
This welding was performed and inspected initially by Bostrom Bergen and was again inspected by Brown & Root (B&R) vendor inspectors.
This item and several 50.55(e) reports have indicated a weakness in the B&R vendor _ surveillance program.
Proper corrective action has been taken to correct this programmatic weakness.
The Board considered management control in this functional area to be of a Category 2 level.
3.
Piping Systems and Supports Region IV has performed very little inspection in this area for two reasons:
(a) NRC efforts have been concentrated on QA programmatic areas, and (b) the volume of work activity has been low.
In-recent months, work has stopped in this area to allow design engineering to catch up, i
The Board did not make an assessment in this functional area.
4.
Safety-Related Components, Including Vessels, Internals and Pumps Work activities in this area have been very low relative to setting equipment because:
(a) status of construction, and (b) sandblast activities inside Unit 1 Containment and Auxiliary Buildings.
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One nonconformance was identified as a generic' problem in IE Report 50-498/81-01; 50-499/81-01:
failure to follow procedure for storage and maintenance of equipment.
Corrective action to date appears to be adequate but final follow-up inspection has not been completed.
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5 Due to limited work, the Board did not assess this area.
5.
Support Systems Including HVAC, Radwaste and Fire Protection lThere was limited work in the areas of radwaste an'd fire protection during the assessment period.
No problems were identified in these areas during this time.
On May 8, 1981, HL&P notified Region IV in accordance with 10 CFR 50.55(e) of a construction deficiency concerning the consideration of certain faulted condition heat loads in the design of portions of the'HVAC system (see item V, 1, b, (10)).
A determination was made, based on an. assessment of preliminary thermal environmental data, that certain spaces and cubicles within the MEAB and FHB would require additional HVAC capacity.
- However, work relating to this item was halted due to changeover of A/Es for STP.
The Board assessed performance in this functional area as Category 2.
6.
Electrical Power Supply and Distribution No work activity has occurred in this area; however, the storage and maintenance has been inspected and appears to be generally I
satis factory.
i No assessment was made in this area.
7.
Instrumentation and Control Systems See item 6, above.
8.
Licensing Activities Licensee activities dealing with licensing requirements have improved significantly during the reporting period.. Responses to requests for information have been timely and of good quality during the reporting period.
Licensee understanding of NRC requirements is adequate.
The Board assessed the licensee's performance in this functional
~
area to be Category 1.
9.
Corrective Actions and Reporting The constructor (B&R) continues to experience difficulty relative to corrective action.
It also appears that the root cause of the problem associated with NRC and licensee identified deficiencies is that the deficiencies are not effectively corrected and are not corrected in a timely manner.
6 Some improvement has been noted, but the constructor has not been able to properly address the issue because of the extreme demands placed on all licensee and contractor organizations by the NRC Show Cause.
Response effort to the NRC Show Cause has resulted in extensive reexamination / repair programs, special technical and QA reviews,' organizational restructuring, numerous personnel changes, and rapid turnover of personnel including key management positions.
In all fairness,.the performance of the constructor site organization should be evaluated during more normal conditions.
Senior licensee and constructor management must continue to be intimately involved with the corrective action process to assure i
that this area is improved.
Licensee reporting of construction' deficiencies in accordance with 10 CFR 50.55(e) requirements has been satisfactory in all respects.
The Board assessed licensee performance in this functional area to be Category 3.
10.
Conclusion 4
The Board based their overall assessment on review of the QA program corrective action and on observing limited work activity caused by the IE Investigation Report 50-498/79-19; 50-499/79-19, Show Cause and Stop Work Orders imposed on Brown & Root, Inc., the prime contractor, by the. licensee. The rating was most heavily influenced by B&R's continued inability to correct the root causes of problems and take corrective action in a timely manner.
The QA program's success is largely dependent upon the correction of the cause of deficiencies.
Although Houston Lighting and Power Company (HL&P) has taken affirmative steps and actions in the area described above,- the implementation of corrective action measures and procedures is still considered a weak area. Therefore, the overall rating for licensee performance is determined to be Category 3,- because of HL&P's inability to compel a significant improvement in B&R's performance in this area.
11.
Board's Recommendations The' Board recommended augmented inspection of the South Texas Project through the transition phase of construction and into restart of construction until performance demonstrates that normal inspection activities may be resumed.
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7 V.
Supporting Data and Summaries 1.
Reports Data LERNumbersReviewed(nokapplicable) a.
b.
Construction Deficiency Reports The licensee's system for reporting construction deficiencies is located in the Houston offices.
Deficiencies identified onsite are forwarded to the Incident Review Committee (IRC) for evaluation.
IE Inspection Report 50-498/81-07; 50-499/81-07 documented a review of this system which included:'(1) reviewing licensee written reports for 1980, and (2) reviewing 58 IRC evaluations from April 26, 1977, to July 3, 1980.
Eleven reports from July 1, 1980, to June 30, 1981, were reviewed and evaluated.
These deficiencies are described below.
(1) Design of Auxiliary Feedwater Pump (All environmental factors not considered in design.)
(2) Breakdown in QA Program Relative to Application of Paint i
to Steel and Concrete Surfaces Except for Liner Plate (3) Reactor Containment Building Structural Steel Beams Loading (4) Unacceptable Surface Condition of Weld in Main Steam Piping and Secondary Shield Wall Whip Restraints (5) Cooling of Primary Shield Wall Penetration Insufficient Air Flow Between Reactor Coolant Nozzle and Seal Plate (6)
Inadequate Cable Tray Hanger Design (7) Hilti Anchor Bolts Design Strength Inadequate (8) American Bridge Structural Steel Welds Deficiencies I
(9) Non-Approved Hilti Revised QA Manual (10) Faulted Condition Heat Loads in Design of Portions of the HVAC System (11) Computer Program Verification A trend was noted relative to the deficiencies reported; that is, 7 of 11 were design problems.
As a result of this trend and other information, a special NRC inspection of the l
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8 design engineering organization was requested on May 27, 1981.
That inspection and review is still in progress and final results are not available, c.
Part 21 Reports The licensee reported two 50.55(e) construction deficiencies as a result of two Part 21 reports which were reported to the licensee.
These items are as follows:
(1) CONSIP Pump Shaft Failure (2) Steam Generator Water Level Measurement System Error 2.
Licensee Activities The licensee's construction activities have been low during the subject period because of the NRC Show Cause Order and Stop Work Orders imposed by the licensee.
3.
Inspection Activities A special team was assigned to follow up on the IE Investigation 79-19 and the Show Cause Order.
This effort continued during the entire reporting period and involved approximately 1318 inspector-hours.
An insignificant number of inspector-hours was devoted to the routine inspection program because of follow-up and reactive inspection.
4.
Investigation and Allegations Review Twelve investigations were conducted during the subject period which involved 756 inspector-hours. These investigations are summarized below:
Subject Results a.
Three allegations relative to Allegations were not confirmed.
(1) painting records, (2) weld rod oven power loss, (3) RCB-2 settlement.
b.
Seven allegations relative to Specification, improper coating; (1) improper specification improper coating records at revision; (2) improper appli-contractor were confirmed.
cation of coatings, (3)
Remainder were not confirmed.
design engineers not O
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9 Subject Results qualified, (4) QC coating records falsified, (5) coat-ing records not authentic, (6) American Bridge coating records incomplete, (7) improper coating repair.
c.
Two allegations relative to The first allegation was (1) B&R foreman intimidating confirmed; however, morale employees, (2) B&R management and personnel problems were took no action on electrical turned over to HL&P department problems.
management.
d.
One allegation relative to Allegation confirmed.
site personnel knowing that an NRC investigation was to occur.
e.
~ Eleven allegations relative All allegations confirmed to (1) B&R intimidation of except unqualified personnel employees, (2) inadequate and concrete form shift.
inspection of materials leaving warehouse, (3) electrical personnel not qualified, (4) concrete form shifted, (5) HL&P/B&R forewarned of NRC' inspection, (6) FREA procedure improper, (7) B&R performing work that j
should not have been performed, (8) low morale, (9) termination shack calibration practices L
improper, (10) B&R did not advise employees of results of employee survey, (11) procurement of electrical supplies improper.
f.
One allegation relative to Allegation not confirmed.
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Four allegations relative to
' Allegation (4) was confirmed (1) electrical' shop records /
.but item was not safety-calibratio,n, (2) storage of related.
safety-related piping in lay.
down area "M", (3) storage of.
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Results safety-related piping in fab shop area, (4).B&R piping isometric drawings differ from specification sheets.
h.
Three allegations relative to Allegation (2) was confirmed (1)'B&R foreman fired because and (3) ha'd "some merit."
he resisted production pressures, (2) B&R rehired personnel formerly fired because of conditions identified in IE Report 79-19, (3) Cadweld records inadequate and falsified.
i.
One allegation relative to Allegation was not confirmed.
drug usa at STP must affect quality of construction.
j.
Five allegations relative to Allegations were not confirmed.
(1) construction deficiencies not properly reported, (2) clearly promoted to project
' quality engineer not qualified,
-(3) B&R auditor at STP not qualified, (4) management intimidated an employee, (5) B&R engineer's experience inadequate for position to which he was to be promoted.
.k.
Four allegations relative to Allegations (1) and (2) were (1)~ designers of STP piping not confirmed, while (3) was systems are not competent, turned over to Region IV i
(2) supervisors signing /
Vendor Inspection Branch.
I approving drawings not competent, (3) Nuclear i
Power Service, Inc., is worst contractor onsite, (4) B&R stress analysis of piping system questioned.
1.
Two allegations relative to Allegations were confirmed.
(1) permanent plant equipment not inspected and records falsified to show inspection results, (2) millwright foreiaan not qualified.
11 5.
Escalated Enforcement Actions a.
Civil Penalties, and b.
Orders The NRC. imposed a $100,000 civil. penalty'and-issued a Show Cause Order to the licensee on April 30, 1980.
The licensee paid the civil penalty and provided a complex and detailed response on July 28, 1980.
In accordance with the Order, on August 19, 1980, a public meeting was-held between,NRC and licensee senior management to discuss the subject response.
Senior representatives from B&R also attended.
These proceedings were documented and placed in the Public Document Room.
As a result of this meeting, HL&P summarized all commitments made in the written response, commitments made between NRC and licensee management, and commitments made at the public meeting in HL&P letter (ST-HL-AE 533) dated September 18, 1980.
Parties to intervene requested that all construction work be stopped but this request was denied.
However, the Commission-did decide to have accelerated hearings on the QA portion for-the operating license to determine the licensee management's character and competence.
These hearings started on May 12, 1981, in Bay City, lexas, and are expected to extend into late fall 1981.
c.
Immediate Action Letters Nine immediate action letters were issued relative to
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confirming stop work actions imposed by the licensee.
The following is a summary.
(1) Issued July 17,1980,. confirming licensee self-imposed Stop Work Order' to check adequacy of controls for AWS welder qualifications and requalifications.
(2) Issued October 3, 1980, confirming licensee's commitments regarding re-examination, repair, and restart of AWS welding.
(3) Issued October 22, 1980, confirming licensee's commitments for additional AWS safety-related welding.
1.7 (4) Issued November 21, 1980, confirming licensee's commitments regarding initiating ASME welding activities.
(5) Issued January 5, 1981, confirming licensee's commitments regarding the ASME safety-related welding 10-Week Work Plan and resumption of safety-related AWS welding.
(6) Issued January 13, 1981, confirming licensee's commitments regarding initiating complex concrete work activities.
(7) Issued February 19, 1981, concerning substitution of certain ASME welding identified in the ASME safety-related welding 10-Week Work Plan.
(8) Issued March 31, 1981, confirming licensee's commitments regarding further limited ASME safety-related welding as outlined in licensee's 12-Week Work Plan.
(9) Issued April 16, 1981, confirming licensee's commitments regarding expanding complex concrete work activities.
6.
Management Conferences Held During Appraisal Period The following were management meetings held during the SALP reporting period:
a.
At the request of the licensee, a management meeting was held on June 17, 1980, to discuss actions being developed regarding Show Cause Order items.
b.
At the request of the licensee, a management meeting was held to discuss actions being taken regarding Show Cause Order items related to Special Investigation 79-19.
c.
November 18, 1980,- to_ discuss status of outstanding Show Cause Order items and restart of work.
d.
March 23, 1981, to discuss restart to ASME welding and current status of Show Cause Order commitments.
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03 C RELE ASE TO UNRES' AREA 08 C 13 C EXCESS R AD. LEVELS 17 C MUF COMPLAINT 04 C LOSS OF F ACILITY 09 C 14 C EXCESS CONC. LEVELS 18 C TR ANSPORTATION 23C PUBLIC INTEREST 05 C PROPE RTY D AMAGE 10 C 19 C CONT AM/LE AKING 240 SA80TAGE SOURCE 25 C ABNORMAL OCCUR 20 C ENVIRONMENT AL EVENT 26C OTHER I
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FOW NR 756 INSPECTeON O ENFOICEMENT - STATISTICAL DATA
- E8RV&MY 1976 8YC 0535' 2
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15 18 V M D L Y '
3 Ag oa OR LICENSE NO 18Y PRODUCT) l6l /l517l TO
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- 2 14 25 30 s""?.e IIIIIIIIIIII II al/loli16l girl M M O O Y Y INSPE CTION *E RFOaME D SY a
1 REGIONAL OFFICE STAFF 2 O RESIDENT INSPECTOR 3 C PERFORMANCE APPRAISAL TEAM vvPE OF ACTivtTY CONDUCTED 'CHECir ONE 80x ONt.Y!
3134 INSPECTION OTHER G
05 C MANAGEMENT AUDif 09 C M ATL ACCT 13 C IMPO RT 14 C INQUIRY C2 C SAFETY 06 C M AN AGEMENT VISIT 10 C PLANT SEC.
I 15 J INVESTIGATION C3 0 sNCIDENT 37X SPECI AL 11 C INVENT VERIF l vit iNvasT. ALso cnecK 04 C ENFORCEMENT Di(C VENDOR 12 C SHIPMENT / EXPORT l stocx si INS *ECTION OR INVEST G ATION WARNING 1 ANNOUNCED 2 0 UNANNOUNCED sNSPECTiON SwC 1 DAY SHIFT 2 COFF SHIFT 3 C WEEKEND / HOLIDAY t
36 iNSPE CTION'iNVE STIG A TION NOfis eC ATION ' CHECK ONE 80x ONLvi J
37 1 C 591 2M REGIONAL OFFICE t.ETTER 3 O REFERRED TO HOS FOR ACTION 4 C REGION LETTER & HOS FOR ACTION
< INSPECTIONaN4 ESTIGATION FINDINGS sCHECK ONE BOX ONLYS K
30 1[ CLEAR 2 C NONCOMPU ANCE 3 C DEVtATION 4 C NONCOMPLI ANCE & DEVIATION L' (NFORCEMENT CONF ERE NCE HE LD: 1C 39
'0 '
M NUMBER OF NONCOMPLI ANCE ITEMS IN LETTER TO LICENSEE.
NoTt: cuaNGE Must se susuiTTro 10! h ON 766 *=thtb Em PmEvious.,Y 47 43 ciTEo TEM 05 NoNeoMPuaNCE ss onociam DELETro Faou N
NUMBER OF DEvlATION ITEMS IN LUTER TO LICENSEE.
l0lCl TwgaEComo 44 45 O
NUMBER OF LICENSEE EVENTS
[ l l 46 INSPECTION FEE 1 C NON-ROUTINE / VENDOR INo Fee 6 2 C ROUTINE INo Feel 3 C ROUTINE (Feet 4 C ROUTINE (Fee Reduced)
O 47 CONTENTS 2.7900 aNFORMATION OT YES REGICNAL OFFICE LETTER OR REPORT TRANSMITTAL DATE FOR INSPECTION OR INVESTIGATION 591 OR LsTTER ISSUED TO LICENSEE REPORT SENT TO HOS FOR ACTION IMMEDIATE ACTION LETTER 48 53 54 59 60 DATE 85 IIIIII I IIIIIII I IIIII I M M D D Y Y M M O D Y Y MM D D Y Y SUBJECT OF INVESTIGATION (CHECK ONE 80x ONLY) 6&67 TYPE A to CF R 20 403 TYPE 8 to CFR 20 405 MISC 01 C INTE RN AL OVE REXPOSURE 06 C 11 C INT. OV E R EXPOSURE 15 C CRITICALITY 21C EQUIP. FAILURE C2 C ExTE RNAL OVE RE xPOSURE 07 C 12 C ExY. OVE REXPOSURE 16 C LOSSsTHEFT 22C ALLEGATION /
5 03C RELEASE TO UNREST AREA C8 C 13 C EXCESS R AD. LEVELS 17 C MUF COMPLAINT l
04 C LOSS OF F ACILtTY 09 C 14 O EXCESS CONC. LEVELS 18 C TR ANSPOR TATION 23C PUBLIC INTEREST 05 C PROPE RT) D AM AGE 10 0 19 C CONTAMILEAKING 240 SABOTAGE SOURCE 250 A8 NORMAL OCCUR 20 C ENvlRONMENTAL
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EVENT 26C OTHER HE AOQUAR TERS ENTRIES T
HOS ACTION ON INSP/tNVEST REFERRED SY REGION l l l is.e ave,. ace L,e e ceae.
70 75 NOTE. eLOCKS K TO N MUST BE U
DATE HOS ENFORCIMENT LETTER. NOTICE. ORDER ISSUED.
l l l l l l l VERIFIED BY IE: HOS M M D D Y Y WHENEVER ENTRIES ARE 76 MADE IN BLOCKS T. U i
AND V V
CavtL PENALTY ISSUED _
77 BC 1I!l l AITS w
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